A Look at the Federal Trade Commission’s Proposed Rule for Auto Dealers from the Perspective of Auto Dealers and Auto Finance Companies, with Special Guests Paul Metrey, Senior Vice President for Regulatory Affairs, National Automobile Dealers Association (NADA), and Richard Hackett, Regulatory Compliance Consultant and former Assistant Director, Consumer Financial Protection Bureau
|Subscribe and Listen|
The FTC’s proposal would impose a number of new substantive and disclosure requirements on auto dealers in connection with the car buying or leasing process. We first discuss NADA’s comment letter to the FTC on the proposal, including NADA’s concerns with the process used by the FTC to issue the proposal and with the proposal’s disclosure, recordkeeping, website posting, and other requirements. We then discuss the auto finance industry’s concerns with the proposal, including the risks arising from the FTC Holder Rule, the industry’s call for safe harbors, and other steps auto finance companies can take to mitigate risks in connection with ancillary products. We conclude with a discussion of the CFPB’s focus on ancillary products, including CFPB supervisory activity, potential areas of CFPB scrutiny, and the CFPB’s use of its authority to supervise auto finance companies to influence dealer behavior.
John Culhane, a partner in Ballard Spahr’s Consumer Financial Services Group, hosts the conversation.
A transcript of the recording will be available soon.
Subscribe to Ballard Spahr Mailing Lists
Copyright © 2023 by Ballard Spahr LLP.
(No claim to original U.S. government material.)
All rights reserved. No part of this publication may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.
This alert is a periodic publication of Ballard Spahr LLP and is intended to notify recipients of new developments in the law. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.